Friends of Science July 5, 2009

Alan Carlin, a senior US Environmental Protection Agency (EPA) research analyst, prepared a report on the science of climate change as comments on the EPA's endangerment analysis for greenhouse gases (GHG). This report was suppressed by EPA officials for political reasons.

The Competitive Enterprise Institute (CEI) published several internal EPA emails which indicate EPA management was suppressing the report. A March 17 email from Mr. McGartland, Office Director of EPA’s National Center for Environmental Economics (NCEE), to Mr. Carlin, stating that he will not forward Mr. Carlin’s study says,

“The time for such discussion of fundamental issues has passed for this round. The administrator and the administration has decided to move forward on endangerment, and your comments do not help the legal or policy case for this decision. …. I can only see one impact of your comments given where we are in the process, and that would be a very negative impact on our office.”

McGartland also forbid him from speaking to anyone outside NCEE on endangerment issues.

Here is a chronological list of developments:

On April 2, 2007, in Massachusetts v. EPA, the Supreme Court found that greenhouse gases are air pollutants covered by the Clean Air Act. The Court held that the EPA Administrator must determine whether or not emissions of greenhouse gases contribute to air pollution which may reasonably be anticipated to endanger public health or welfare, or whether the science is too uncertain to make a reasoned decision.

One ofUS President Barack Obama’s first acts since his inauguration on January 20, 2009 was to write a memo to agencies demanding new transparency in government and science.

In response, EPA Administator Lisa Jackson, said that she will ensure EPA’s efforts "are rooted in three fundamental values: science-based policies and program, adherence to the rule of law, and overwhelming transparency."

On April 24, 2009, the EPA issued an ‘endangerment’ finding on anthropogenic greenhouse gases, including carbon dioxide (CO2). It establishes that CO2 is a pollutant, and would thereby givethe EPA the authority to regulate it. The EPA’s endangerment document "Proposed Endangerment and Cause or Contribute Findings for Greenhouse Gases Under Section 202(a) of the Clean Air Act" dated April 17, 2009 is here. A Technical Support Document (TSD) includes many of the detailed references to science, data, and models used to justify comments in the Endangerment Finding. It is here.

The EPA set a 60 day comment period, where interested parties may submit comments on the endangerment finding. The deadline for submission of comments was June 23, 2009. The EPA had received more than 4000 comments by the deadline. Some selected comments are here. The EPA is required to consider the comments before issuing a final endangerment finding.

On June 24, the CEI published a set of four internal EPA emails dated March 12 - 17, 2009 which indicated there was a significant internal EPA report critical of the EPA's endangerment finding.

On June 26, the CEI released a draft copy of the suppressed EPA report by Alan Carlin critical of the EPA’s position on carbon dioxide.

On June 26, 2009, by a vote of 219 Yes, 212 No, the Waxman-Markey Climate Bill is passed by the US House of Representatives. The full text of the bill, including a 300 page amendment, was released at 3:00 AM on the day of the vote. The bill would impose cap and trade rules and restrict energy use. An analysis by the Heritage Foundation shows the bill will cost Americans $160 billion in 2020, rising to $585 billion per year by 2035, or $6,800 for a family of four.

On June 29, 2009 US Republican senator Inhofe ordered an investigation into the EPA's suppression of the report that questioned the science behind global warming.

On June 30, 2009 the CEI issued a statement demanding that the EPA allow public comments on an internal global warming report that the agency itself suppressed. Also on June 30, Carlin had an interview with FOX News where he discussed the suppression of his report.

The EPA emails raise several serious issues.

The end result of withholding Mr. Carlin’s study was to taint the Endangerment Proceeding by denying the public access to important agency information. US court rulings say rule-making records must include both "the evidence relied upon and the evidence discarded." In refusing to allow Mr. Carlin's study to be circulated, the agency essentially hid it from the docket.

CEI says "The EPA emails also suggest that EPA has prejudged the outcome of this proceeding, to the point where it arguably cannot be trusted to fairly evaluate the record before it. Courts have recognized “the danger that an agency, having reached a particular result, may become so committed to that result as to resist engaging in any genuine reconsideration of the issues.”

Finally, the emails suggest that EPA’s extensive pronouncements about transparency and scientific honesty may just be rhetoric. The EPA apparently doesn’t care about any negative comments of their GHG Endangerment findings, even internally, and makes a mockery of the public comment process.

Alan Carlin's report is an excellent summary of climate science. It is on the Friends of Science website General Climate Science section here, see the "Comments on Endangerment Analysis for Greenhouse Gas Emissions". While there are several excellent reports critical of the AGW theory, this report may get more attention as a subject of a Senate investigation.

This report includes many graphs and comments by FoS Director Ken Gregory, with links to the Friends of Science website. If fact, whole sections are copied directly from the FoSClimate Change Science Essay. See pages 24 - 26, 54 -55, 57 - 61. (Gregory's name appears 20 times in Carlin's report.)

Mr Carlin’s report advised that the scientific hypothesis on which the draft legislation is based is seriously flawed. He lists its failings as:

1. Lack of observed upper tropospheric heating in the tropics

2. Lack of observed constant humidity levels, a very important assumption of all the International Panel on Climate Change (IPCC) models, as CO2 levels have risen.

3. The most reliable sets of global temperature data we have, using satellite microwave sounding units, show no appreciable temperature increases during the critical period 1978-1997, just when the surface station data show a pronounced rise. Satellite data after 1998 is also inconsistent with the GHG/CO2/AGW hypothesis.

4. The models used by the IPCC do not take into account or show the most important ocean oscillations which clearly do affect global temperatures, namely, the Pacific Decadal Oscillation, the Atlantic Multidecadal Oscillation, and the ENSO. Leaving out any major potential causes for global warming from the analysis results in the likely misattribution of the effects of these oscillations to the GHGs/CO2 and hence is likely to overstate their importance as a cause for climate change.

5. The models and the IPCC ignored the possibility of the indirect impacts of solar magneticvariability, which if important would again be likely to have the effect of overstating the importance of GHGs/CO2.

6. The models and the IPCC ignored the possibility that there may be other significant natural effects on global temperatures that we do not yet understand. This possibility invalidates their statements that one must assume anthropogenic sources in order to duplicate the temperature record.

7. Surface global temperature data may have been hopelessly corrupted by the urban heat island effect and other problems which may explain some portion of the warming that would otherwise be attributed to GHGs/CO2. In fact, the Draft TSD refers almost exclusively in Section 5 to surface rather than satellite data.

Carlin says, “These inconsistencies between the TSD analysis and scientific observations are so important and sufficiently abstruse that in my view EPA needs to make an independent analysis of the science of global warming rather than adopting the conclusions of the IPCC and CCSP without much more careful and independent EPA staff review than is evidenced by the Draft TSP. Adopting the scientific conclusions of an outside group such as the IPCC or CCSP without thorough review by EPA is not in the EPA tradition anyway, and there seems to be little reason to change the tradition in this case."

The Draft TSD is based largely on the IPCC Fourth Assessment Report (AR4) which is out of date, and does not consider natural causes of climate change. The report lists the following important developments since the AR4:

Global temperatures have declined, with a rapid decline in 2007 - 2009.

The consensus on future hurricane behavior has changed, from the idea the global warming may lead to more and intense hurricanes to the current consensus that warming will have an insignificant effect on hurricanes.

The fear the Greenland will rapidly loose ice has been greatly diminished by new results indicating the ice movement has slowed significantly over the last 17 years.

The current rate of GHG emissions is greatly decreased compard to the assumptions made by the IPCC.

New research finds the climate models' crucial assumption of a strong positive feedback from water vapour is wrong, and that the feedback is actually negative.

New research suggests the solar variability could account for up to 68% of the increase in Earth's global temperatures.